Procedural Posture
Plaintiff former employee, who suffered from bipolar disorder, sued defendants, a corporate parent of several fast food franchises and plaintiff's immediate supervisor, for public disclosure of private facts. The Orange County Superior Court, California, granted summary judgment in favor of defendants and entered a judgment of dismissal. Plaintiff appealed.
Overview: fraud caci
The basis of the suit was the supervisor's alleged disclosure to plaintiff's coworkers of her bipolar condition. The court held that disclosure in a writing is not required to maintain a cause of action for public disclosure of private facts. Oral disclosures can be just as harmful as written disclosures. The requirement that a public disclosure be in writing was the only basis for the trial court's ruling on defendants' motion for summary judgment. Because plaintiff did not allege a violation of the constitutional right to privacy, she was not entitled to have the summary judgment motion evaluated for constitutional privacy. The trial court properly refused to consider plaintiff's arguments on this theory of liability.
Outcome
The judgment of dismissal was reversed.